Motor Vehicles Act, 1988 – Sections 165 & 166 – Maintainability of claim petition – Mere involvement of motor vehicle – Whether sufficient to fasten liability – Held, No.
The deceased Anand travelled in the appellant's motor vehicle on 29-11-2009. Three days later, his dead body was recovered. Though the appellant was initially convicted, he was subsequently acquitted in the criminal proceedings. The claimants sought compensation under Sections 165 and 166 of the Motor Vehicles Act alleging that the deceased was murdered in the appellant's vehicle. The Supreme Court held that mere involvement or presence of a motor vehicle in the chain of events does not fasten liability under the Motor Vehicles Act. To maintain a claim under Sections 165 and 166, the claimant must establish a causal nexus between the use of the motor vehicle and the death or injury. In the absence of evidence connecting the injuries or death with the use of the vehicle, the claim is not maintainable. Since there was no forensic, ocular, or other evidence establishing such nexus, the MACT had no jurisdiction to award compensation. Accordingly, the awards of the Tribunal and the High Court were set aside.
Ratio Decidendi: A claim under Sections 165 and 166 of the Motor Vehicles Act is maintainable only when the claimant establishes a causal nexus between the use of the motor vehicle and the death or injury. Mere presence or involvement of a motor vehicle in the chain of events or surrounding circumstances is insufficient to fasten liability under the Act.
2026 INSC 736
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